HomeMy WebLinkAbout13-4264 Supreme Court of Pennsylvania For Prothonotary Use Only:
Court of Common Pleas Docket No: t {
Civil Cover Sheet
CUMBERLAND County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings and other papers required by law or rules of the court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
S
E Lead Plaintiffs Name: Lead Defendant's Name:
C CITIBANK, N.A. TAMMY CRIDER
T
I
O Any money damages requested ?: ® Yes ❑ No Dollar Amount Requested: a within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
Name of Plaintiff/Appellanfs Attorney: Brit J. Suttell, Esquire
❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant)
Nature of the Case Place and "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Possession ® Debt Collection: Credit Card ❑ Board of Assessment
S ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
E ❑ Nuisance ❑ Depart. of Transportation
C ❑ Premises Liability ❑ Statutory Appeal: Other
T ❑ Product Liability (does not ❑ Employment Dispute:
I include mass tort) Discrimination
O ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
N ❑ Other: ❑ Other:
B ❑ Other:
MASS TORT
❑ Asbestos
❑ Tobacco
• Toxic Tort - DES
• Toxic Tort - Implant
❑ Toxic Waste
❑ Other:
REAL PROPERTY MISCELLANEOUS
❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
• Dental ❑ Partition ❑ Replevin
• Legal ❑ Quiet Title ❑ Other:
• Medical ❑ Other:
• Other Professional:
F C" CE
�' -' F t r'i 1'
{. ! 1 1 , i ic I F1D 0
2013 JUL 22 PH 12: 37
CUMBERLAND CDUNITY
PENNSYLVANIA
Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire ID. NO. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696 -2120
Attorney for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
TAMMY CRIDER : NO.
205 Middle Spring Road �3 - �a�
Shippensburg PA 17257 -8615
Defendant CIVIL ACTION -LAW
Complaint - Notice
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within (20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to
the claim set forth against you. You are warned that if you fail to do so, the case may proceed without
you and a judgment. may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERENCE AND INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717- 249 -3166 or 800 - 990 -9108
C -61497 / 304
BURTON NEIL & ASSOCIATES, P.C.
Derek C. Blasker, Esquire, Id. No. 202150
Brit J. Suttell, Esquire, Id. No. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610 - 696 -2120
Attorney for Plaintiff
CITIBANK, N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N
Sioux Falls, SD 57117
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. /3 _ ��
�
TAMMY CRIDER �
205 Middle Spring Road
Shippensburg PA 17257 -8615
Defendant CIVIL ACTION -LAW
Complain
1. Plaintiff is Citibank, N.A. with place of business located at 701 East 60th Street
North, Sioux Falls, South Dakota.
2. Defendant is Tammy Crider who resides at 205 Middle Spring Road, Shippensburg,
Cumberland County, Pennsylvania.
3. Plaintiff is a national banking association, engaged in various types of banking
business including consumer lending through the issuance of credit cards.
4. Defendant obtained extensions of credit from Citibank, N.A., successor in interest to
Citibank (South Dakota), N.A., by means of a Sears credit card account (hereafter the Account)
with account number ending in 8775.
f
5. Citibank (South Dakota), N.A. merged into Citibank, N.A. in or about July 2011.
6. Accurate records of all debits and credits to the Account were maintained by plaintiff.
7. Defendant was provided with monthly statements for the Account including the billing
statement attached hereto as Exhibit A (redacted to remove confidential information). The
monthly statements accurately stated the previous balance and the debits and credits to the
Account for the prior billing period.
8. Defendant had for many months after receipt of a billing statement made payment on
the Account or retained the statement without payment.
9. Defendant retained the Exhibit A statement without making payment by the stated due
date.
10. Defendant's assent to the Account balance set forth in the Exhibit A statement is
manifested through the prior conduct of defendant either making payment on the Account or
retaining the statement without payment, after receipt of the monthly billing statements.
11. As a result of said assent, an account stated for the sum of $3,364.57 exists which
sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent
to the date of Exhibit A.
Wherefore, plaintiff demands judgment against defendant for the sum of $3,364.57, and
the costs of this action.
B on ss ciat s, P.C.
B Der C. Blask , Esquire
Y: Brit J. Suttell, Esquire
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
C -61497 / 205
Account Statement
Send Notice of Billing Errors and Customer Service Inquiries to:
Customer Service: SEARS CREDIT CARDS
seats Box 6282, Sioux Falls, SD 57117 -6282
Premier MasterCard ® A ccount Inqu iries:
1-800 669- 8488
Accoutlt 1�7umber 873
Summary of Account Activity Payment Information
Previous Balance $3,261.14 New Balance $3
- Payments 0.00 Minimum Payment Due $1
Other Credits 0.00 Payment Due Date May 20, 2013
Purchases 0.00
Cash Advances +$0.00 Late Payment Warning: If we do not receive your minimum payment by the
Fees Charged +$35.00 date listed above, you may have to pay a late fee up to $35.
Interest Charged +$68.43 Minimum Payment Warning: If you make only the minimum payment each
New Balance $3,364.57 period, you will pay more in interest and it will take you longer to pay off your
balance. For example:
Past Due Amount $641.14 .:.::.:- .......... . . .
if you make t1a adcllttonal Yot1 wlti pay'f the pnc# .
you well
Credit Limit 0.00 c#larges usttlgt[ils card baiaiiceshawnon this encf up paytrig "art
Available Credit 0.00 Bach month you pay ; statement tri about esfimated total:of
:...
Cash Advance Limit $0.00 Only the minimum payment 14 years $7,645
Available Cash Limit $0.00 $134 3years $4,831
Amount Over Credit Limit $474.57 1 (Savings= $2,814)
Statement Closing Date 04/23/2013 if you would like information about credit counseling services, call 1 -877- 337 -8188.
Next Statement Closing Date 05/24/2013
Days in Billing Cycle 30
Your account is seriously past due. Amount past due is shown above. Arrangements for future payments should be made immediately.
TRANSACTIONS
Trans Date Description Reference # Amount
FEES
04/20 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD $ 35.00
INTEREST CHARGED
04123 INTEREST CHARGE ON PURCHASES $ 68.43
TOTAL INTEREST FOR THIS PERIOD $ 68.43
This spring is a good time to take care of your past due amount
Let us work with you, and together we can find a payment solution that may help bring your account current and avoid future late fees.
» Call 1-866- 518 -9049 today and our trained Account Specialists will help you explore your payment options
For our TDD line call 1- 800 -926 -5818
8ME15
PLEASE SEE IMPORTANT INFORMATION ON PAGES 2 AND 4. Page 1 of 8 This Account is Issued by Citibank, N.A.
d Please detach and return lowerportion with yc urpayment to insure proper credit_ Retain upperp2giiRr for Your records_ -- y
sears ® Your Account Number is 8775
Payment Due Date May 20, 2013
PO BOX 6286 Thank you for making New Balance $3,364.57
SIOUX FALLS, SD 57117 -6286
at least your Past Due Amountt $641.14
Minimum Payment Due Minimum Payment Due $1,253.14
Statement Enclosed
each month. :'Amount Encfrised �;
tPast Due Amount is included in the Minimum Payment Due.
Please print address changes on the reverse side.
Make Checks Payable tow
SEARS CREDIT CARDS
TAMMY CRIDER PO BOX 183082
205 MIDDLE SPRING RD COLUMBUS, OH 43218 -3082 EXHIBIT HIBIT A
SHIPPENSBURG, PA 17257 -8615 p
02100 0125314 0336457 0012000 3775 1518
Information About Your Account. Proper Form. For a payment sent by mail or courier to be in proper form,
How to Avoid Paying Interest on Purchases. Your payment due date is you must:
at least 25 days after the close of each billing cycle. We will not charge you Enclose a valid check or money order. No cash, gift cards,
any interest on purchases if you pay Your Nev: Balance by the payment or foreign currency please.
due date each month. This is called a grace period on purchases. If you do Include your name and the last four digits of your account number.
not pay the New Balance in full by the payment due date, you will net get
a grace period on purchases until you pay the New Balance in full for two Payment Other Than By Mail.
billing cycles in a row. We will begin charging interest on cash advances and on-Store (Where Available). Any payment in proper form accepted in-
balance transfers (it available on your account) on the transaction date. store will be credited as of that day. However, credit availability may be
If you have a balance subject to a deferred interest promotion and that subject to verification of funds. Not all stores accept payments. Contact
promotion does not expire before the payment due date, that balance (the your local story to see if in-store payments are accepted at that location.
"excluded promotional balance ") is excluded from the amount you must Online. Go to the URL on Page 1 of your statement to make a pavment.
pav in full to get a grace period. However, you must still pay any separately For security reasons, you may not be able to pay your entire Ne��
required payment on the excluded promotion. In billing cycles in which Balance the first time you make a payment online. The payment cutoff
payments are allocated to deferred interest balances first, the deferred time for Online Bill Payments is midnight Eastern time. This means that
interest balance will be reduced before any other balance on the account. we will credit your account as of the calendar day, based on Eastern
However, you will continue to get a grace period on purchases so long as time, that we receive your payment request.
you pay the New Balance less any excluded promotional balances in full by AutoPay. Sign up at Account Online to have your payment amount
the payment due date each billing cycle. automatically deducted each month trom the account you choose.
In addition, certain promotional offers may take array the grace period on Your card account will be credited on the clue date with that amount.
purchases. Other promotional offers not described above may also allow Phone. Call the phone number on Page 1 of your statement to make
you to have a grace period on purchases without having to pay all or a a payment. We may process your payment electronically after we
portion of the promotional balance by the payment due date. It either is verify your identity. The payment cutoff time for Phone Payments is
the case, the promotional otter will describe what happens. midnight Eastern time. This means that we will credit your account
How We Calculate Your Balance Subject to Interest Rate. We use a as of the calendar day, based on Eastern time, that we receive your
daily balance method (including current transactions) to calculate interest payment request.
charges. To find out more information about the balance computation Express Mail. Send payment by courier or express mail to: Payments
method and how the resulting interest charges were determined, contact Department, 1500 Boltonfield Street, Columbus, OH 43228. Payment
us at the Account Inquiries number an the front. must be received in proper form at the proper address by 5 p.m. Eastern
time to be credited as of that day. All payments received in proper form
Balance Transfers. Balance transfer amounts are included in the
at the proper address after that time will be credited as
"Purchases" line in the Summary of Account Activity (if balance transfers
of the next day.
are available on your account)-
Transaction Date. The Transaction Date shown on the statement is also a you send et eligi or payment with this payment t. If we , you authorize
us to complete your payment by electronic debit. if we do, the checking
the Sale Date. account will be debited in the amount on the check. We may do this as
Other Account and Payment Information. soon as the day we receive the check. Also, the check will be destroyed.
Payment Amount. You may pay all or part of your account balance at
any time. However, you must pay, by the payment due date, at least the
minimum payment due.
When Your Payment Will Be Credited. If we receive your payment in
proper form at our processing facility by 5 p.m. local time there, it will be
credited as of that day. A payment received there in proper for after that
time will be credited as of the next day. Allow 5 to 7 days for payments by
regular mail to reach us. There may be a delay of up to 5 days in crediting a
payment we receive that is not in proper form or is not sent to the correct
address. The correct address for regular mail is the address on the front of
the payment coupon. The correct address for courier or express mail is the
Express Mail Address shown in the Express Mail section.
T03174
PLEASE SEE IMPORTANT INFORMATION ON PAGE 4 S1v1C,TG1lS0GISCP'HIPs -2 APR13
Page 2 of 8
Change of Address
Please print address changes in blue or black ink.
Account: * * ** * * ** * * ** 8775
Total Fees Charged in 2013 $140.00
Total Interest Charged in 2013 $261.15
INTEREST CHARGE CALCULATION Your Annual Percentage Rate (APR) isthe annual interest rate on your account.
Typeof'Bafar►ce`' AnnualPercentageRate(APR ;:iB�anceSub)ect +tolnterestRbte IrateiestGtiarge, ;
PURCHASES
REGULAR 25.24% (D )(V) $3 $68.43
CASH ADVANCES
REGULAR 27.15% (D )(V) 0.00 $0.00
Variable Rate D = Dai
Page 3 of 8
Credit Reporting Disputes. If you think we reported inaccurate After we finish our investigation, one of two things will happen:
information to a credit bureau write uS at the Customer Service address If w m ade a mist You will not have to pay the amount in question
shown on Page 1. or any interest or other fees related to that amount.
Report a Lost or Stolen Card Immediately. Call the Account Inquiries if we do not believ there was a mistake: You will have to pay the
number shown on Page 1. amount in question, along with applicable interest and fees. We will
What To Do If You Find A Mistake On Your Statement send you a statement of the amount you owe and the date payment
If you think there is an error on your statement, write to u<_ at the is due. We may then report you as delinquent if you do not pay the
address for billing errors and customer service inquiries shown on amount we think you owe.
Pagel of your statement. if you receive our explanation but still believe your bill is wrong, you
In your letter, give us the following information: must write to us within 10 day telling us that you still refuse to pay.
If you do so, we cannot report you as delinquent without also reporting
Account information Your name and account number- that you are questioning your bi II. five must tell you the name of
Dollar amount The dollar amount of the suspected error. anyone to whom we reported you as delinquent, and we must let those
Description of problem If you think there is an error on your bill, organizations know when the matter has been settled between us.
describe what you believe is wrong and why you believe it is a mistake. If we do not follow all of the rules above, you do riot have to pay the
You must contact us: first $50 of the arnount you question even if your bill is correct.
Within 60 days after the error appeared on your statement. Your Rights It You Are Dissatisfied With Your Credit Card Purchases
At least 3 business days before an automated payment is scheduled, If you are dissatisfied with the goods or services that you have purchased
if you want to stop payment on the amount you think is wrong. with your credit card, and you have tried in good faith to Correct the
You must notify us of any potential errors in writing You may call us, problem with the merchant, you may have the right not to pay the
but if you do we are not required to investigate any potential errors and remaining amount due on the purchase.
you may have to pay the amount in question. To use this right, all of the following must be true:
What'dtiti Ha"±n After We Receive Your Letter 1. The purchase must have been made in your home state or within 100
When we receive your latter, we must do two things: miles of your current mailing address, and the purchase price must
have been more than $50. (Note: Neither of these are necessary if
1. Within 30 days of receiving your letter, we must tell you that your purchase was based on an advertisement we mailed to you, or
we received your letter, We will also tell you if we have already if we own the company that sold you the goods or services.)
corrected the error. 2. You must have used your credit card for the purchase. Purchases
2. Within 90 days of receiving your letter, we must either correct made with cash advances from an ATM or with a check that accesses
the error or explain to you why we believe the bill is correct. your credit card account do not qualify.
While we investigate whether or not there has been an error: 3. You must riot yet have fully paid for the purchase.
We cannot try to collect the amount in question, If all of the criteria above are met and you are still dissatisfied with the
or report you as delinquent on that amount. purchase, contact us in writin at the address for billing errors and
The charge in question may remain on your statement, customer service inquiries shown on Page -- i of your statement.
and we may continue to charge you interest on that amount. While we investigate, the same rules apply to the disputed amount as
While you do not have to pay the amount in question, discussed above. After we finish our investigation, we will tell you our
you are responsible for the remainder of your balance. decision. At that point, if wtie think you owe an amount and you 00 not
We can apply any unpaid amount against your credit limit- pay, We may report you as delinquent.
EM
T03175 -ME- 1238-5300- 0022- P- E -87 -X- 10/01/04- 80 —P -0-5- 402 -0-0---01 /25/13 -GDWB -March 24, 2013 -0-0 -V
N—
PLEASE SEE IMPORTANT INFORMATION ON PAGE 2 SMCrrGI!SCC!SCP /HIPS -4 APR13
Page 4 of 8
01/13
075
WHAT DOES CITIBANK DO WITH
YOUR PERSONAL INFORMATION?
........ _......_..._.._...._......_.... ...... ... -_... _._...._".._ ..... ... ....... .__._..__.._._..........__._ ............ ...... - ....
_.._......_._ .._...._._....- ._....__.._..._.
t..• Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
. a • i
_ Federal law also requires us to tell you how we co llect share and p rotect
your personal information. Please read this notice carefully to understand
se� - what we do.
�_.. .......... ......................................................................:........................................ .............. ..............
............
✓ The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
._.r
•Social Security number and income
' �� • account balances and employment information
-- credit history and transaction history
All financial companies need to share customers' personal information
to run their everyday business. In the section below, we list the reasons
financial companies can share their customers' personal information; the
reasons Citibank chooses to share; and whether you can limit this sharing.
I A,'� < } C . ] ,,A� _ S ��S H•Y;iK#'� V.M .. }�� �5 +�1.� 1� `r � 17 � 1 �+FF
.i�„'�,��?rh�vt•�i S�F(.�'�.�� - ��>� .gae�t'tf4 -_"S�^ , tc�, -; is '� �,. �,`?rzus �rav { .'�,aob;c`� - ts`�'.�'�t`��'�r' :c ai
For our everyday business purposes -
such as to process your transactions,
'maintain your account(s), respond to court Yes No
orders and legal investigations, or report
to credit bureaus
'For our marketing purposes -
to offer our products and services to you Yes No
- _... -- - - - -..... - - .._.._..._._..... ........... ... ...........
..........._ .............._..._._.._.....+
i For joint marketing with other Yes No
;financial companies
For our affiliates' everyday business
purposes - information about your Yes No
,transactions and experiences
- ......._._.. -- .._..
For our affiliates' everyday business
purposes - information about your Yes Yes
creditworthiness
I For our affiliates to market to you Yes Yes
_.__......_.......
............... _.._....__ ...................... ..... . .
For our nonaffiliates to market to you Yes Yes
........... .----------------------- :..._..______-__..___.__......__..__.._..-..__..__.....-_.._..__.._...._..__ .... .......................___..__. _.._...._..__....._... -
n ................................._........_..._... ....- ...- .__................... ..........
.. Call 1- 877 - 491 -0609 - our menu will prompt you through your choice(s). I
g� f Please note:
If you are a new customer, we can begin sharing your information 30 days
from the date we sent this notice. When you are no longer our customer, we
continue to share your information as described in this notice.
Gam` However, you can contact us any time to limit our sharing.
ME
Call 1- 877 - 491 -0609 or call the Customer Service number on the back of
your credit card or on your billing statement.
u _......._._._......__......_..__....... __._......___._ .._.....___..__.._._..._..__.._ .._._ ............. ........ ... _ "......_........___...
Page 5of8
01/13
076
Who is providing You are receiving this notice from the retail partner cards group of
;this notice? Citibank, N.A., the bank that issues your credit card.
How does Citibank To protect your personal information from unauthorized access and use, we
protect my personal use security measures to comply with federal law. These measures include
information? ! computer safeguards and secured files and buildings.
How does Citibank We collect your personal information, for example, when you
i collect my personal • provide account information or give us your contact information
information? • provide employment information or apply for a loan
• use your credit or debit card
We also collect your personal information from others, such as credit
bureaus, affiliates, or other companies.
......... ........ ........... ...__.._..__ ..............._..... ...__.....__......_.._..._.._.. .._..._.._..__.._..__.._...._..
Why can't I limit Federal law gives you the right to limit only
;all sharing? • sharing for affiliates' everyday business purposes —
information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you.
State laws and individual companies may give you additional rights to limit
sharing. See below for more on your rights under state law.
MM
Affiliates Companies related by common ownership or control. They can be financial
land nonfinancial companies.
• Our affiliates include companies with a Citi name; financial companies
such as Citigroup Global Markets Inc. and Banamex USA.
Nonaffiliates - Companies not related by common ownership or control. They can be
;financial and nonfinancial companies.
• Nonaffiliates we share with can include companies engaged in direct
marketing and the selling of consumer products and services.
._. .............. ....__.._.._ ... .... ... - ._.... _. __...__. ..._...---- ... ........ ......... _...._... _. ..._..._.._..... -
Joint marketing A formal agreement between nonaffiliated financial companies that
'together market financial products and services to you.
...:
54 g� C II P e .'e' # rt � P 6 9 = C - '�.;. ' � i + ,�F$ty Y '�Ya��, • +r �2...� -- x�.^�
P '�9't'�"�.;,,r ` ,, h� _. ..+ti'�a��: ,�a�td� ..�� ,.._: �, 3�.�"���"�t�- �fi:�s ✓k 'r��` r i ... .� �.N..t�.
For Vermont Residents: We will not share information we collect about you with nonaffiliated third'
parties, except as permitted by Vermont law, such as to process your transactions or to maintain your
account. In addition, we will not share information about your creditworthiness with our affiliates except
with your authorization.
I For California Residents: We will not share information we collect about you with nonaffiliated third;
parties, except as permitted by California law, such as to process your transactions or to maintain your
l account.
We may share your, personal information, as permitted by taw, with the retailer whose name is on your
card and with the companies related to the retailer. You cannot limit this sharing.
Important Information about Credit Reoortinq
We may report information about your account to credit bureaus. Late payments, missed payments or
other defaults on your account may be reflected in your credit report.
..
............... .. ............. ................... ....... ...— ............ ............ ._.._.. .........
......_...
Page 6 of 8
d ,
Your new statement: n
i
Clear: Your statement usos a large easy to read font and everyday language that s ��mple
to understand
Concise.: The information !s' grouped so you can quickly identify your recent activity, totaF balance
minimum payrrient minimum payment dice date and how ieng ! #may fake to pay off your tjalarace;
.. . .
� " � ' � ;� MW MM AISi9 ec�r � a4az Att�L' arc AMIX AfANI AUA9 MW =W ,Off AMC MW AOW , ARW . ,'tt» MM'
i
Account (dumber/
Contact Information
Account Statement
.a..Lm �»
Summary of Account Activity i 6 ,ai1Dµveo: wimp rru <.rrn + +z`
Outlines monthly account
� , b195ti2NJlf :bxt_�:.899998099%9,)998.
activity, including payments 5u nrnory MdeeoLn zo:iv ary ment /nlumsJOn
credits, fees and interest Yayn ' v 94 W N P-W.`e _09Q4 °°'4a
)en15_ :- F9...4.444.!14 Mon An P. -. nUe - S4 00040n V -
charged Ot wr cipl"s 54.444.444.44 P.,I—I M". rive NVsnr: rx) YYYY
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PIitY iC,¢'.:: .S4 94!+449 49
. CmnAtlri � ..-�'.- fSU W!+,94440 Lae Pafinem Warnng. O:•nr.,F:xnv yw mn-un t' =.mxn n:
' - _.____ -. .. —_ . .: ...... .... �v•firs N,'Mn:.tis {•t' -xy �n,.'r ts,yxl•�f,s.q'ntn '�.`.
' F'44F Ch9Y4eE._ _ _ .549WP44A4
t„t���r f$.W4.9�� alninm Rymer" Weminq'v.,.: in.•{a nnv nsmnm.nn Pra�r.�
Payment Information ' 4w Dn4ve9. x4494,444w M.., ,,.II >.,. ,,,:;Ia rsl „tl:l E Le yy vy l..
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ConsO HTnYS AM 2013
Page 7of8
Page 8of8
Verification
I, Ashley C00 , am employed by Citibank, N.A. (hereafter Citibank), which
is successor in interest to Citibank (South Dakota), N.A. This includes accounts previously
owned by Citibank (South Dakota), N.A. which merged into Citibank in or about July 2011. I
am authorized to make this verification on behalf of Citibank. The statements of facts set forth in
the Complaint are true and correct upon my information and belief and are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
f
Date: - Signature
C -61497
Tammy Crider
Account number ending 8775
1032
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriffresttu?
Jody S Smith �{ =
Chief Deputy k� M
Richard W Stewart CIJ1 BERL.AND cow in,
,
Solicitor .FTkm�SP RIFa PENNSYLVANIA
Citibank, N.A. Case Number
vs. 2013-4264
Tammy Crider
SHERIFF'S RETURN OF SERVICE
07/29/2013 03:50 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Tammy Crider at 205 Middle Spring Road, Southampton Township, Shippensburg, PA 17257.
611— /Lv. 4 —
SON KINSLER, DEPUTY
SHERIFF COST: $50.60 SO ANSWERS,
July 30, 2013 RONW R ANDERSON, SHERIFF
(c)Coun[ySuite Sheriff,Teleosof;,Inc.
C-61497/221
CITIBANK,N.A. IN THE COURT OF COMMON PLEAS
701 East 60th Street N, Sioux Falls, SD 57117
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. ?
NO. 13-4264 CIVIL
TAMMY CRIDER W
z M rr,
205 Middle Spring Road M;:0 -0
Shippensburg PA 17257-8615 -<A cn'
Defendant : CIVIL ACTION-LAW c C5 low
�-
Praecipe for Default Judgment vC=
To the Prothonotary: C
r< C:5 rLl
Please enter judgment by default for want of an answer in the above case in favor of the
plaintiff and against the defendant, and assess damages as follows:
Princi}al: $3,364.57
Less Credits: $85.00
TOTAL $3,279.57
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. §
4904 relating to unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment debtor and creditor.
2. The annexed notice of intention to file this praecipe was mailed to all parties against whom
judgment is to be entered and to their record attorneys, if any, after the default occurred,and at least
ten days prior to the date of the filing of this praecipe.
3. Pursuant to Section 201(b)(1)(A)of the Servicememb r Civil Relief Act of 2003(SCRA),
the defendant is not in the military service of the United States as d on information received from
the defendant and/or the Department of Defense website.
JUDGMENT BY DEFAULT ENTERED B &Associates, P.C.
AND DAMAGE ASSESSED AS ABOVE.
NOTICE GIVE NDfnT V.P. 236 By:
Dee C. Blasker, Esquire
Attorn for Plaintiff
Pro Prothon �' I.D. NO. 202150
1060 Andrew Drive, Suite 170
West Chester, PA 19380
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
soP(�
Moh Xal��c�
C-61497/265
CITIBANK,N.A. IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 13-4264 CIVIL
TAMMY CRIDER
Defendant : CIVIL ACTION -LAW
TO: Tammy Crider
205 Middle Spring Road
Shippensburg PA 17257-8615
DATE OF NOTICE: August 21,2013
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by attorney and file in
writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10)
days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your
property or other important rights. You should take this paper to your lawyer at once. If you do not have a lawyer,
go to or telephone the office below. This office can provide you with information about hiring a lawyer.
If you cannot afford to hire a lawyer,this office may be able to provide you with information about agencies that
may offer legal services to eligible persons at a reduced fee or no fee.
LAWYER REFERENCE AND
INFORMATION SERVICE
Cumberland County B Assoc.
32 South Bedford reet
Carlisle, PA 170
Telephone No. 717-249-3166 0-990-9108
Burt it& Associates,P.C.
By:
Derek la •er, Esquire
Attorney for P intiff
This is an attempt to collect a debt,and any information Identification N '. 202150
obtained will be used for that purpose. This 1060 Andrew Drive, Suite 170
communication is from a debt collector. West Chester, PA 19380
(610) 696-2120